Ethics & Compliance

At Booz Allen, our commitment to operating with the highest ethical standards goes hand in hand with our purpose and values. Our Code of Business Ethics and Conduct describes and mandates how we put our ethical standards, values, and purpose into action. Together they guide our firm and inform how we engage with our clients, competitors and partners, and other external stakeholders.

Our Ethics and Compliance program helps our people understand their important role and responsibilities in creating our culture of integrity. It provides leadership and establishes rules around how we as a firm strive to do what is right while operating our business in compliance with applicable laws and regulations, including laws governing anticorruption, competition, data privacy, and international trade compliance, among others. The program is anchored in key controls and processes, driven by our risk management mission, and supported by the effort we invest in regularly assessing our risks and controls. Our chief ethics and compliance officer leads the program and, along with a team of ethics and compliance professionals, receives oversight and guidance from our executive-level Ethics and Compliance Committee and the Board of Directors Audit Committee.

To equip our people with the information they need to live our value of ferocious integrity, we use firmwide training and awareness-building campaigns designed to keep important ethics and compliance topics top of mind. Through our firmwide Ethics Advisors program, we provide designated employees who serve in this role with resources and education on ethics and compliance topics, which they in turn share and discuss with their colleagues. The ethics advisors serve as a force multiplier for the Ethics and Compliance program, acting as ambassadors who relay information, as well as an intake channel to whom employees can report compliance or ethics concerns. We also host an annual Ethics and Compliance Week, which has included panels of senior firm leaders speaking about the importance of operating with integrity, along with leaders from our Investigations team, who drive greater transparency by speaking about our investigations process and internal system of organizational justice. Throughout the year, we celebrate and reward employees who exemplify our values and demonstrate the firm's commitment to ethics and compliance. During our Ethics Week celebration, we honor and showcase employees who live our value of ferocious integrity through their words and actions with our Ethics Champions awards—one of the highest awards Booz Allen offers employees.

Mandatory Training

We require firmwide, annual Ethics and Compliance training to help guide employees and provide them with the information needed to live our purpose and values and to adhere to our Code of Business Ethics and Conduct. Additional role-based training is required of some employees, such as those who handle certain types of sensitive or entrusted information or serve as people leaders. The firm-mandated training covers a variety of risk-based focus areas, such as data privacy and protection, information security, competition, anticorruption, organizational conflicts of interest, time reporting, use of social media, and intellectual property, among others.

Commitment to Continuous Improvement

We regularly survey our people to gauge the effectiveness of our ethics and compliance initiatives, assess our firm's culture, and obtain feedback on how we can make our program even more useful and effective as we move forward in an always-evolving regulatory environment. We also conduct comprehensive risk assessments and benchmarking exercises to evaluate our key and emerging compliance risk areas. This enables us to identify new requirements and risks, determine whether program enhancements are needed to address these requirements and risks, and assess whether the program is operating as designed. Our compliance monitoring function drives and facilitates the use of data to inform our risk assessment process, strategic planning efforts, and program assessments.

Our Commitment to Nonretaliation

We rely on all Booz Allen employees to promptly escalate concerns about our firm's business or business practices. This information is vital to honoring our commitment to cultivate an ethical culture and stay true to our purpose and values. We provide multiple avenues for our people to do so, including our Ethics Helpline, which is always available and provides the option to report issues anonymously. We have a network of more than 150 employees serving as ethics advisors, another firm reporting channel, to whom employees can report concerns outside of their management chain. We also provide channels outside of Legal, Ethics, and Compliance (LEC) to report concerns regarding the LEC function or its members, and these reports are subject to investigation by non-LEC resources. Our Ethics Helpline is also available to our suppliers, clients, and the general public to report concerns. Every report is evaluated and, if appropriate, investigated by our Legal Investigations and/or Employee Relations teams. Booz Allen strictly prohibits retaliation against anyone who raises a concern in good faith..

Technology-Enabled Compliance

We enhance our Ethics and Compliance program through the use of technology. Over the past year, we implemented several new and enhanced existing technology solutions, including an integrated Ethics Reporting Helpline and Investigations Case Management System, Policy Management System, Conflict of Interest Disclosure Management System, Policy Library, and Third-Party Risk Management System. These systems help provide us with greater data-driven insights and align with our continuous improvement mindset.

Looking ahead, we will continue to evolve our program to align with our ongoing organizational transformation and changes in the regulatory environment. This includes clear and robust policies to drive desired employee behaviors, targeted and content-driven training and communications, an increased focus on transparency, enhancing our risk assessment process along with our data analytics, monitoring, and testing capabilities, more robust engagement with business leaders, and maturing our practices related to our third-party ecosystem, which includes suppliers, business partners, and clients.